Jeff A. Wiltzius, Transferee - Page 23

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          before the liquidation.  We disagree.  That was before the last              
          return for the years in issue was due from House of Babes.  The              
          Commissioner could assess tax for House of Babes' earliest                   
          taxable year in issue, 1984, at least until March 15, 1988, and              
          beyond that if House of Babes committed fraud.                               
               Petitioners contend that imposing transferee liability on               
          them is unlawful double taxation.  We disagree.  Respondent is               
          trying to collect House of Babes' taxes; no prohibited double                
          taxation is present here.                                                    
               Petitioners contend that section 6901(a)(1)(A) does not                 
          authorize respondent to collect an amount equal to 100 percent of            
          the value of the property they received from House of Babes.  We             
          disagree.  Respondent may collect the lesser of (1) the                      
          transferor's tax liability, including additions to tax and                   
          interest, or (2) the value of the assets the transferee received,            
          plus interest.  Peterson v. Sims, 281 F.2d 577 (5th Cir. 1960);              
          Mysse v. Commissioner, 57 T.C. 680, 703 (1972).                              
               3.   Conclusion                                                         
               We conclude from the badges of fraud that are present here              
          that House of Babes fraudulently intended (through its                       
          shareholders) to transfer its assets to its shareholders with                
          intent to delay payment of its creditors.  Harper v. United                  








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